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The AT dismissed both review applications. The review by the appellant was held meritless because the impugned findings constituted an appreciation of materials on record by a co-ordinate bench and did not disclose any error apparent on the face of the record; such factual findings are not reversible in review. The regulator's review was likewise dismissed as hyper-technical, the WTM and AO having adjudicated on the same factual matrix, and no prima facie error warranting review was demonstrated. The Tribunal noted that the AO's orders have been set aside and remitted for fresh disposal, but declined to entertain either review, ordering both applications dismissed.
The AT dismissed both review applications. The review by the appellant was held meritless because the impugned findings constituted an appreciation of materials on record by a co-ordinate bench and did not disclose any error apparent on the face of the record; such factual findings are not reversible in review. The regulator's review was likewise dismissed as hyper-technical, the WTM and AO having adjudicated on the same factual matrix, and no prima facie error warranting review was demonstrated. The Tribunal noted that the AO's orders have been set aside and remitted for fresh disposal, but declined to entertain either review, ordering both applications dismissed.
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TaxTMI 
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